DRAFT ANALYSIS OF BROWNFIELDS CLEANUP ALTERNATIVESgaryin.us/redevelopment/wp-content/uploads/sites/2/... · Cleanup Alternatives Cost Analysis ... North Central, LLC (WCG) has prepared

PREPARED BY

January 21, 2019

Project No.: 1940-300-01

DRAFT ANALYSIS OF BROWNFIELDS CLEANUP ALTERNATIVES

CITY OF GARY REDEVELOPMENT COMMISSION

Parcel 5 Buffington Harbor 6200 Industrial Highway

Gary, Indiana

Weaver Consultants Group North Central, LLC

J:\PROJECTS\1900-1999\1940\300\01 USEPA GRANT APPLICATION\ABCA\DRAFT ABCA (PARCEL 5 - GARY).DOCX 1/21/19

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TABLE OF CONTENTS

1 INTRODUCTION .......................................................................................1

2 BACKGROUND ...........................................................................................2

2.1 Property Description ..................................................................2

2.2 Property History ..........................................................................2

2.3 Proposed Redevelopment .........................................................3

3 SUMMARY OF PROPERTY CHARACTERIZATION ...........................4

3.1 Prior Investigations ....................................................................4

Phase I ESA ...................................................................................... 4 3.1.1

Limited Phase II ESA ........................................................................ 4 3.1.2

3.2 Property Geology and Hydrogeology ....................................6

4 CLEANUP ALTERNATIVES ANALYSIS ................................................7

4.1 Cleanup Goals ................................................................................7

4.2 Soil Cleanup Alternatives Analysis.........................................7

Alternative 1 – No Action ................................................................ 8 4.2.1

Alternative 2 – Debris Pile Onsite Reuse and Capping ................... 8 4.2.2

Alternative 3 – Offsite Disposal of Contaminated Materials from 4.2.3Debris Piles ...................................................................................... 8

Cleanup Alternatives Cost Analysis ................................................. 9 4.2.4

4.3 Proposed Remedial Action .......................................................9

4.4 Cleanup Schedule .........................................................................9

LIST OF FIGURES

Figure 1 – Property Location Map

Figure 2 – Property Layout Map

Figure 3 – Proposed Remedial Area Location



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1 INTRODUCTION

On behalf of the City of Gary Redevelopment Commission (GRC), Weaver Consultants Group

North Central, LLC (WCG) has prepared this Analysis of Brownfields Cleanup Alternatives

(ABCA) report for the property located at 6200 Industrial Highway in Gary, Indiana, as shown on

Figure 1 – Property Location Map (the Property). This ABCA report was prepared in support of

ongoing activities to evaluate cleanup alternatives to mitigate potential risks to human health

and the environment from identified subsurface environmental impacts at the Property.

On behalf of the GRC, WCG conducted a Phase I Environmental Site Assessment (ESA) in May

2018 (report dated August 13, 2018) and a Limited Phase II ESA in June 2018 (report dated

August 13, 2018) to identify and assess recognized environmental conditions (RECs) with

respect to the Property. The GRC is submitting an application to the United States

Environmental Protection Agency (USEPA) for a Brownfields Cleanup Grant (RFP Number EPA-

OLEM-OBL-18-07) which will be used to fund the cleanup activities described herein.

The remediation area, addressed under this ABCA report, includes the remediation of

contaminated material from an approximate 155,000-cubic yard stockpile that includes process

waste (e.g., lime, cement, and slag) from the former cement plant operations, construction

demolition debris, and other fly dumped materials. This pile is located in in the central-eastern

portion of the approximate 78-acre Property (refer to Figure 2 – Property Layout Map). The

purpose of this proposed cleanup is to meet environmental regulatory requirements for the

Property to be redeveloped for industrial/commercial property uses.

This ABCA report has been prepared in support of the USEPA Grant Application and is available

for public review and comment. The GRC shall consider all comments received and provide

responses to those comments in a timely manner. Upon responding, a Record of Decision will

be prepared and published for public review by the GRC.

Should the USEPA Grant be awarded, the GRC will obtain Request for Proposals/Qualifications

and Bids from multiple remediation contractors, including local qualified companies. The

USEPA Brownfields Grant Project Officer will be contacted once a remediation contractor has

been selected.



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2 BACKGROUND

2.1 Property Description

The Property is located at 6200 Industrial Highway in Gary, Indiana. The Property generally lies

north of Industrial Highway, east of Buffington Harbor Drive, and south and west of North Clark

Road (refer to Figure 1). The Property consists of one parcel with an approximate area of 78-

acres and approximately 1,100 feet of frontage along Buffington Harbor Drive. As shown on

Figure 2, there are two remaining buildings on the Property associated with the former

occupant Lehigh Portland Cement: Building 35 and Building 20H. Building 35 is 44,000 square

feet and Building 20H consists of fifteen (15) 115-foot tall concrete silos with an approximate

footprint of 15,000 square feet. The eastern portion of Building 35 is partially demolished and

is used for the storage of pallets, cardboard, and other general refuse. The central portion of

Building 35 is currently utilized by the Majestic Star Casino for the storage of casino records and

patio furniture. Building 20H (former storage silos) is currently empty. In addition, there is a

small single-story concrete building located east of Buffington Harbor Drive. Multiple piles of

materials consisting of concrete, soil, rebar, wood, slag, foundry sand, and/or other unknown

material, ranging in height from approximately five to twenty (20) feet, were observed on the

central to northwestern portions of the Property. In addition, Buffington Harbor Road occupies

approximately three acres on the western portion of the Property.

A review of the Whiting and South Highland, Indiana, 1998, 7.5-minute quadrangle topographic

map published by the United States Geological Survey (USGS) suggests that the Property is at

an elevation approximately 590 to 595 feet above mean seal level (msl) and slightly slopes to

the northwest towards Lake Michigan.

2.2 Property History

According to historical records, the northern portion of the Property was improved with a

railroad by at least 1900 and by at least 1908, the western portions of the Property and the

northern adjoining property and the western adjoining property were developed for utilization

as a cement production facility. Operations at the facility included industrial activities

associated with the manufacturing of Portland cement and calcium aluminate cement products.

By 1938, the western portion of the Property appeared improved with at least seven buildings,

several access roads, a conveyor belt system, and a smoke stack. The eastern portion of the

Property appeared improved with at least four rail spurs. The Property remained in this general

configuration until at least 1967. Between 1967 and 1970, the rail spurs on the eastern portion



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of the Property appeared to have been removed and/or generally inactive and a large pile of

unknown material is visible in the central-eastern portion of the Property. Between 1973 and

1983, at least four of the buildings located on the Property appeared to have been razed and

the Property remained in this general configuration until at least 1998.

The Lehigh Portland Cement Company reportedly owned the facility from 1980 until 2001.

Following the cement plant closure in or around 2000, the GRC acquired the western portions

of the Property and northern adjoining property and the western adjoining property for the

development of lakefront areas. Subsequently, Barden Companies, Inc. purchased this site and

established Gary New Century, LLC. After going through bankruptcy proceedings, the site was

purchased by the Majestic Star Casino, LLC in 2004 and sold to the current owner, the GRC, in

2014. Between 1998 and 2005, all but two of the historical Property buildings appeared to

have been razed, Buffington Harbor Drive appeared improved on the western portion of the

Property, and additional piles of unknown material appeared to be stored on the central to

northwestern portions of the Property.

2.3 Proposed Redevelopment

The future use of the Property is intended to be for industrial/commercial purposes. A biofuels

company Fulcrum BioEnergy has expressed interest in developing a biofuel plant on the

Property. The plant will convert solid waste into low-carbon, renewable transportation fuel

with construction expected to begin in 2020 and continue for eighteen (18) to twenty-four (24)

months until completion. Once operational, the plant would process a dry, clean feedstock of

paper, plastic, and other waste products. After gasification, these materials would be

converted into a jet fuel that would reduce greenhouse gas emissions by an estimated eighty

(80) percent.



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3 SUMMARY OF PROPERTY CHARACTERIZATION

3.1 Prior Investigations

Reviewed documentation includes the following:

1. Phase I ESA dated August 13, 2018 and prepared for the GRC by WCG; and

2. Limited Phase II ESA dated August 13, 2018 and prepared for the GRC by WCG.

The environmental assessment activities that have taken place on the Property are described in

the following subsections.

Phase I ESA 3.1.1

At the time of the Phase I ESA site reconnaissance, the Property was improved in its current

configuration with the three remaining Lehigh Portland Cement facility buildings and material

stockpiles.

The following REC was identified in connection with the Property during the Phase I ESA:

The potential presence of surface and subsurface impacts associated with the reported

dumping on the Property and the observed piles of materials consisting of concrete, soil,

rebar, wood, slag, foundry sand, and/or other unknown materials, from at least 1973 to

present day.

In addition, the following controlled recognized environmental condition (CREC) was identified

in connection with the Property during the Phase I ESA:

The known and potential presence of surface and subsurface impacts with a No Further

Action (NFA) Determination associated with the historical industrial use of the western

portions of the Property and the northern adjoining property, and the western adjoining

property as the Lehigh Portland Cement facility. The NFA Determination was issued

with an Environmental Restrictive Covenant (ERC) which indicates that the western

portions of the Property and the northern adjoining property, and the western adjoining

property cannot be used for residential or agricultural purposes and that the parking

structure on the northern adjoining property over the area of SS-14 where

polychlorinated biphenyl (PCB) impacts were identified must be maintained.

Limited Phase II ESA 3.1.2

The Limited Phase II ESA was conducted to assess the environmental conditions related to the

observed piles of materials consisting of concrete, soil, rebar, wood, slag, foundry sand, and/or



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other unknown materials. This effort included the advancement of eight soil probes to

approximately fifteen (15) feet below ground surface (bgs) and the installation of three

temporary monitoring wells to approximately twelve (12) feet bgs. The soil probes and

temporary monitoring wells were generally advanced surrounding the material stockpiles. Soil

and groundwater samples were collected from each of the soil probes and monitoring wells for

laboratory analysis. In addition, sixteen (16) test pits were excavated from the material

stockpiles in support of preliminary geotechnical exploration activities and sample collection.

WCG collected soil samples from nine of these sixteen (16) test pits for laboratory analysis. .

Soil and groundwater samples exhibiting impacts in excess of Indiana Department of

Environmental Management (IDEM) Screening Levels presented in the 2018 IDEM Screening

Level Table A-6, updated March 7, 2018 include the following:

Four soil probes and eight test pits included samples exhibiting various metal

concentrations in excess of Residential, Commercial/Industrial, and/or Excavation

Screening Levels;

One test pit included a sample exhibiting various volatile organic compound (VOC)

concentrations in excess of Residential Screening Levels;

Two test pits included samples exhibiting naphthalene concentrations in excess of the

Residential Screening Level;

One test pit included a sample exhibiting a PCB concentration (Aroclor-1242) in excess

of the Residential Screening Level; and

Three groundwater samples exhibited various total metal concentrations in excess of

the Residential Tap Groundwater Screening Levels. The dissolved metal concentrations

in these samples were below laboratory reporting limits or the Residential Tap

Groundwater Screening Levels, with the exception of dissolved mercury in one

groundwater sample and dissolved arsenic and lead in one groundwater sample.

In addition, a black “tar-like” material was observed within a damaged 55-gallon steel drum and

on surrounding soils within one test pit. Remnants of at least four additional steel drums were

also observed within the top four feet of this test pit. As a result of the above, the material

piles must be disposed as a waste material.



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3.2 Property Geology and Hydrogeology

The following interpretation of the subsurface conditions is based on the eight soil probes

advanced as part of the Limited Phase II ESA. The following includes a summary of subsurface

soils that were encountered during investigation activities:

Topsoil underlain by fill material was observed from the ground surface to

approximately 0.25 feet bgs in three soil probes. Fill materials were observed at the

surface in the remaining soil probes. The fill materials generally consisted of silty sand,

gravel, refractory sand, brick, concrete, slag, and/or gravel and extended to depths of

approximately 3.5 to eight feet bgs;

The fill material was underlain by native poorly graded sand to depths of approximately

fifteen (15) feet bgs, the maximum depth explored. Lenses of well-graded gravel were

also observed in soil probes three soil probes between 12.5 and fifteen (15) feet bgs.

Saturated soils were encountered within each soil probe between three and eight feet bgs.

Groundwater was encountered in the temporary wells at depths ranging from approximately

two to six feet bgs.



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4 CLEANUP ALTERNATIVES ANALYSIS

The Property is currently unused with the exception of the eastern portion of Building 35 that is

used for the storage of pallets, cardboard, and other general refuse. The central portion of

Building 35 is currently utilized by the Majestic Star Casino for the storage of documents and

patio furniture. Future land use at the Property and remediation area is planned to be

industrial/commercial. The cleanup goals reflect the objective of minimizing the environmental

considerations that may need to be considered during development and construction, and

subsequent operation and maintenance of facilities.

The cleanup includes the remediation of contaminated material from an approximate 155,000-

cubic yard stockpile that includes process waste (e.g., lime, cement, and slag) from the former

cement plant operations, construction demolition debris, and other fly dumped materials. This

pile is located in the central-eastern portion of the Property (see Figure 3 – Proposed

Remediation Area Locations). Based on the results of the aforementioned Limited Phase II ESA

activities, it is anticipated that approximately five percent of this stockpile (7,000 to 8,000 cubic

yards) is contaminated material that will have to be disposed in a Subtitle D Landfill. Removal

of the stockpiles in this area will allow for future redevelopment.

4.1 Cleanup Goals

The cleanup activities will be conducted under the oversight and review of IDEM. The Property

will be enrolled in the IDEM Voluntary Cleanup Program (VCP) in order to obtain a “Comfort

Letter” for the proposed redevelopment. The intent of the cleanup is to reduce the

contaminated surficial debris pile and any associated impacted soils exceeding IDEM Screening

Levels in the central-eastern portion of the Property that could act as a source for further

contamination to soil and groundwater, mitigate exposure to humans and the environment,

and mitigate exposure to end users or construction workers during redevelopment. Any

remaining IDEM Screening Level exposure route exceedances may be addressed through

engineering and institutional controls (e.g. engineered barriers, construction worker

notification, and deed restrictions).

4.2 Soil Cleanup Alternatives Analysis

The cleanup alternatives considered for mitigating the risks associated with the impacted soil

are discussed below.



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Alternative 1 – No Action 4.2.1

A no-action alternative was considered as part of the ABCA process and would be the least

expensive alternative. Under this scenario, the surface conditions would remain as-is. A no-

action alternative does not include a cost that would be incurred.

Although no action is the least costly, it does not achieve the GRC’s plan to redevelop the

Property, create jobs, and bring the Property back to productive use. Therefore, the debris

piles must be remediated to protect human health and the environment, and thus the no-

action alternative was eliminated from further consideration.

Alternative 2 – Debris Pile Onsite Reuse and Capping 4.2.2

A reuse onsite and capping alternative was considered as part of the ABCA process. This would

include the use of the existing debris piles onsite as structural and non-structural fill in support

of future redevelopment activities at the Property. The contaminated soil material would be

used as-is, while the asphalt and concrete material would be pulverized using a crusher.

Following the site grading, contouring, and compacting of the former debris piles, the

contaminated debris pile material would be required to be capped using asphalt or concrete

pavement. An onsite reuse and capping alternative would cost approximately $1,000,000 to

$1,500,000.

The onsite reuse and capping alternative would be the most expensive alternative.

Additionally, based on the preliminary geotechnical investigation activities, at least half of this

material is structurally unsuitable for use as a base in support of redevelopment activities, such

as the construction of buildings and parking lots.

This alternative assumes approximately 7,000 to 8,000 cubic yards of contaminated material

from the 155,000-cubic yard pile is proposed for onsite reuse and capping. Actual costs would

be based upon remediation contractor proposals obtained prior to implementation. The

alternative costs include the applicable regulatory reporting requirements, programmatic and

general project management, as well as field contingencies and applicable IDEM review fees.

Costs for treating all of the impacted soils to “clean” conditions are not included.

Alternative 3 – Offsite Disposal of Contaminated Materials from Debris Piles 4.2.3

An offsite disposal alternative was considered as part of the ABCA process. This would include

the excavation, loading, transportation and disposal of the contaminated material from the

approximate 155,000-cubic yard stockpile at a permitted Subtitle D disposal facility in



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accordance with applicable local, state, and Federal regulations. An offsite disposal alternative

would cost approximately $475,000 to $600,000

This alternative assumes approximately 7,000 to 8,000 cubic yards of contaminated material

proposed for removal and disposal at a Subtitle D Landfill. Actual costs would be based upon

remediation contractor proposals obtained prior to implementation. The alternative costs

include the applicable regulatory reporting requirements, programmatic and general project

management, as well as field contingencies and applicable IDEM review fees.

Cleanup Alternatives Cost Analysis 4.2.4

Alternative Cost

Alternative 1: No Action $0

Alternative 2: Debris Pile Onsite Reuse and Capping $1,000,000 - $1,500,000

Alternative 3: Offsite Disposal of Contaminated Materials

from Debris Piles $475,000 - $600,000

4.3 Proposed Remedial Action

On the basis of effectiveness, costs, time constraints, future land use goals and site plans,

regulatory criteria and technical feasibility, WCG recommends Alternative 3 – Offsite Disposal

as the most appropriate alternative to remediate impacted soils. Under WCG’s direction, the

remediation contractor will excavate, load, transport of dispose of the contaminated material

from the pile depicted on Figure 3.

4.4 Cleanup Schedule

Pending USEPA, IDEM, and public approval, the GRC tentatively plans on conducting the

remediation activities prior to planned construction in 2020. Once the USEPA Grant is awarded,

the GRC will obtain Request for Proposals/Qualifications and Bids from multiple remediation

contractors, including local qualified companies. The USEPA Brownfields Grant Project Officer

will be contacted once a remediation contractor has been selected. It is anticipated that

remediation will begin within two to three weeks following the finalized contract and all

approvals are received.

APPROXIMATEPROPERTY LOCATION

COPYRIGHT © 2019 WEAVER CONSULTANTS GROUP. ALL RIGHTS RESERVED. 1 inch = ft.

APPROXIMATE GRAPHIC SCALE

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750

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300015001500

CHICAGO, ILLINOIS(312) 922-1030 www.wcgrp.com

REVIEWED BY:

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CAD:

DRAWN BY:

REUSE OF DOCUMENTSTHIS DOCUMENT, AND THE DESIGNS INCORPORATED HEREIN, AS AN INSTRUMENT OF PROFESSIONAL SERVICE, IS THE

PROPERTY OF WEAVER CONSULTANTS GROUP, AND IS NOT TO BE USED IN WHOLE OR IN PART, WITHOUT THE WRITTENAUTHORIZATION OF WEAVER CONSULTANTS GROUP. FIGURE 1

PROPERTY LOCATION MAPBUFFINGTON HARBOR - PARCEL 5

6200 INDUSTRIAL HIGHWAYGARY, IN

WeaverConsultantsGroup

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SOURCE: IMAGE ADAPTED FROM GOOGLE EARTH IMAGERY DATED MARCH 2018.

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Documents

DRAFT ANALYSIS OF BROWNFIELDS CLEANUP ALTERNATIVESgaryin.us/redevelopment/wp-content/uploads/sites/2/... · Cleanup Alternatives Cost Analysis ... North Central, LLC (WCG) has prepared